Although implementation of a law to require clinical decision support (CDS) use involving diagnostic imaging orders was pushed back from 2018 to 2020, medical organizations are asking Congress to consider modifications to reduce the burden on clinicians.
In 2014 Congress passed the Protecting Access to Medicare Act (PAMA), which will require referring providers to consult appropriate use criteria (AUC) prior to ordering advanced diagnostic imaging services for Medicare patients. If the ordering provider does not consult AUC rules via clinical decision support before the order is placed, CMS will not pay the for the imaging.
In a recent letter, physician organizations representing primary, specialty and surgical care asked lawmakers to modify PAMA in such a manner that healthcare professionals who meet the requirements of the Medicare Quality Payment Program (QPP) will be deemed compliant with the AUC Program.
The medical organizations argue that AUC consultation is inherent within the Quality Payment Program’s dual tracks: the Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs), both of which hold clinicians accountable for quality and patient outcomes, as well as for resource use. For instance, they wrote, there are a number of existing measures for appropriate use of imaging in the Quality category of the QPP. In addition, CMS has added consultation of AUC as an Improvement Activity within MIPS — essentially folding key aspects of this program into MIPS.
They stress that requiring clinicians to participate in a stand-alone AUC reporting program, in addition to the cost reduction and value-based activities of the QPP, will be “burdensome, duplicative and costly, and due to a lack of appropriate measures, will not aid in determining whether patients are better served by the program’s implementation.”
Because AUC reporting is congressionally mandated, any changes to the program require legislative action. The groups ask Congressional leaders to modify the law to afford clinicians maximum flexibility in the use of AUC in the least administratively burdensome manner possible while meeting the intent of PAMA to ensure appropriate imaging through enhanced education of ordering professionals and support for clinicians in achieving high-value performance in MIPS or APMs.
In January 2018 Healthcare Informatics reported on a Society for Imaging Informatics Management webinar in which imaging informatics executives discussed their efforts to get ready of the AUC requirements.